Treat them as governance gaps, not exceptions. If a system holds accounts, entitlements, or local credentials, it belongs in the identity control boundary even if the platform cannot connect immediately. Prioritise the systems with the highest privilege concentration, then create a measurable backlog for onboarding and verification.
Why This Matters for Security Teams
Systems that sit outside identity governance tools are not harmless blind spots. They are often where local admins, service accounts, API keys, and one-off exceptions accumulate without review. That creates uneven enforcement, weak evidence for audits, and an easy path for privilege sprawl. NHI Management Group research shows that 88.5% of organisations say their non-human IAM practices lag behind or merely match human IAM, and only 5.7% have full visibility into service accounts in the Ultimate Guide to NHIs.
The right response is to treat disconnected systems as scoped identity risk, not as an operational nuisance. The control boundary should follow where accounts, entitlements, and secrets actually exist, even if the governance platform cannot ingest them yet. That framing matters because audit teams, incident responders, and IAM owners need a consistent way to rank exposure, document compensating controls, and drive onboarding. The broader identity baseline in the NIST Cybersecurity Framework 2.0 supports that approach by tying asset visibility to access governance outcomes. In practice, many security teams discover these systems only after an incident, an audit request, or a failed offboarding review has already exposed the gap.
How It Works in Practice
Start by building a shadow inventory of every system that holds identities outside the governance platform. That includes legacy applications, appliances, managed file transfer tools, embedded platforms, CI/CD runners, and partner-facing systems. For each one, capture three things: what identities exist, what privileges they hold, and whether secrets can be rotated or revoked centrally. This is where current guidance suggests treating the system as part of IAM even if the tool cannot connect to it yet.
Use risk-based prioritisation instead of trying to onboard everything at once. High-value targets are systems with privileged local accounts, long-lived credentials, poor logging, or shared access. Map those to the same lifecycle expectations described in the Ultimate Guide to NHIs and to identity governance principles from CISA Zero Trust Maturity Model, especially least privilege, continuous verification, and access review.
- Assign an owner for every disconnected system and make onboarding a tracked backlog item.
- Require compensating controls such as manual reviews, vaulting, or break-glass approval until tool coverage exists.
- Set measurable criteria for onboarding: account discovery, entitlement mapping, secret rotation, and deprovisioning evidence.
- Verify that the system can support current-state reporting before considering it “covered.”
If a system cannot be connected technically, move to a documented control alternative, such as periodic exports, reconciliation scripts, or attested manual review. The CIS Critical Security Controls are useful here because they reinforce inventory, access control, and secure configuration even when integration is incomplete. These controls tend to break down when the system is owned by a separate operations team with no agreed data export or admin access model, because identity evidence cannot be collected reliably.
Common Variations and Edge Cases
Tighter control of disconnected systems often increases operational overhead, requiring organisations to balance speed against assurance. In older environments, the problem is not just missing integration but missing primitives: no API, no export, no central vault support, and no reliable audit trail. Best practice is evolving here, and there is no universal standard for how much manual evidence is enough. The decision should be based on privilege level, business criticality, and how quickly the system can be brought under governance.
Some teams also need to distinguish between temporary exclusions and permanent exceptions. A short-term exemption may be acceptable for a lab, pilot, or vendor-managed appliance, but it still needs expiry dates and named owners. For legacy platforms, the highest-value mitigation is often credential reduction, not full automation. That can mean removing shared accounts, moving secrets into managed storage, or constraining access to a small set of break-glass operators. The Top 10 NHI Issues and Ultimate Guide to NHIs — Regulatory and Audit Perspectives both reinforce the same practical point: auditors will ask how disconnected identities are governed, not whether the platform had a connector on day one. The hard cases are systems with privileged local admins and no exportable identity data, because they force teams into manual controls that are easy to defer and hard to prove.
Standards & Framework Alignment
This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.
OWASP Non-Human Identity Top 10 address the attack and risk surface, while NIST CSF 2.0 and NIST AI RMF set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| OWASP Non-Human Identity Top 10 | NHI-01 | Disconnected systems often hide unmanaged NHIs and secrets. |
| NIST CSF 2.0 | ID.AM-2 | Assets and identity dependencies must be identified to manage gaps. |
| NIST AI RMF | GOVERN | Governance requires accountability for exceptions and control gaps. |
Inventory every unmanaged account and secret, then bring each system into the NHI control boundary.
Related resources from NHI Mgmt Group
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Reviewed and updated by the NHIMG editorial team on June 23, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
